VIRGINIA: IN THE CIRCUIT COUR OF THE CITY OF ALEXANDRIA JANICE WOLK GRENADIER Plaintiff Vs.

DAVID MARK GREANDIER Defendant PLAINTIFFS OPPOSITON TO DEFENDANTS MOTIONS FILED ON AUG 26, 2013. 1. DEFENDANTS OPPOSITION TO MOTION TO COMPEL 2. DEFENDANTS OBJECTIONS TO REQUEST FOR PRODUCTION OF DOCUMENTS AND THINGS AND RESERVATION ON SANTIONS AND ATTORNEYS FEES COMES NOW, the Plaintiff STATES THE FOLLOWING addressing each Motion in the above order. 1. DEFENDANTS OPPOSITION TO MOTION TO COMPEL (Re: Yoav Katz) The subpoena follows the law to the T. Was accepted by the Clerks office, Certified that copies went to attorneys for Defendant, along with e-mails ignored by the Defendant and his attorneys prior to it being filed and served. That Defendants attorneys should know the law to quash or object to such Subpoena as they are trying to do with the Request for Production of Documents. By appearance Defendants attorneys are inclusion to obstruct justice and ignore the law. Yoav Katz also had a right to object to the Subpoena and he did not. Defendant and his attorneys should be sanctioned. As already stated several times in other documents filed with this court. 2. DEFENDANTS OBJECTIONS TO REQUEST FOR PRODUCTION OF DOCUMENTS AND THINGS AND RESERVATION ON SANTIONS AND ATTORNEYS FEES Defendant and his family ( his family has been brought into this by defendants council in her motion) have slandered Plaintiff, filed false documents with this court, Lied in this court and committed several other criminal acts against Plaintiff. The actions of Defendant and his family have been actions that are willful acts that were and still

CH. NO. 99-1253 Opposition to Defendants Motions

are malicious, violent, oppressive, fraudulent, wanton, or grossly reckless.

The law is very clear and Defendant used Fraud with the collusion of his family in harming Plaintiff and her girls.
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The following Attached Exhibits are just a few that Plaintiff will offer into evidence: 1. As a lawyer Ilona Ely Grenadier Freedman Heckman tried to force Plaintiff into signing attached Parenting and Separation Agreement Which as an attorney was illegal and unethical of her and her law firm. Exhibits 1 & 2 2. Letter dated May 20, 1985 Which states that the Forged Addendum that Ilona Grenadier a lawyer who would then with the help of her law firm went on to steal from the Sonia Grenadier Trust. An e-mail by Defendants sister will show that she and others believed the late Judge Albert Grenadier did have a will and that substitute Trustee Duvalle knew it. On this Letter you will see in Defendants hand writing to get rid of Duvalle as Trustee. Defendant was being paid by the law firm of Ilona Grenadier to do as he was instructed to do by her. Plaintiff will be able to show the stealing from Sonia Grenadier by all appearance started much earlier than 1985. 3. Letter December 6, 1985 again instructions on the front page in Defendants hand writing. 4. Attached an accounting by Yoav Katz That shows Mrs. Katz was being disingenuous and most likely in collusion with Defendant and his family when she said they didnt use computers, and had no records. Plaintiff through witnesss and documents will be able to show the collusion bet ween Defendant and his family that there actions were and still are willful acts that were and still are

malicious, violent, oppressive, fraudulent, wanton, or grossly reckless. The law is

very clear and Plaintiff used Fraud with the collusion of his family in harming Plaintiff. That Plaintiff was the only one to pay back any of the funds stolen by Ilona Grenadier and her law firm. That the Real Estate purchased while married and prior Plaintiff has a claim to by marital rights, and funds that were comingled. That Defendant and his family were disingenuous and conspired the evening David pulled a gun on Plaintiff while the girls were in the home. The defendant had witness that lied in the Commissioners hearing for him. That the evidence will show that Defendant and his family used the threat of harming the girls to control Plaintiff.
September 5, 2013 Janice Wolk Grenadier 15 West Spring Street Alexandria, Virginia 22301 jwgrenadier@gmail.com 202-368-7178

Certificate of Service
I hereby Certify that a true copy of the following was e-mailed and Hand Delivered to Defendants Counsel Lana Manitta of LMManitta@rrbmdk.com, Rich RosenthalBrincefield Manitta Dzubin & Kroeger, LLP - 201 North Union Street, Suite 230, Alexandria, VA 22314 - Phone: 703.299.3440. September 5, 2013 Janice Wolk Grenadier